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New Reporting Rules for Nonbank Financial Institutions in Wartime

New Reporting Rules for Nonbank Financial Institutions in Wartime

The NBU provides recommendations to nonbank financial institutions on how to submit and publish reports and other information intended for the regulator under martial law.

Reporting Requirements

Providers of nonbank financial services should, where possible, submit and publish reports within the time limits established by the Rules for the Compilation and Filing of Reports with the National Bank of Ukraine by Nonbank Financial Services Market Participants, approved by NBU Board Resolution No. 123 (hereinafter referred to as the Rules No. 123) dated 25 November 2021, and other requirements of the laws.

At the same time, in line with the Law of Ukraine On Protecting the Interests of Entities Submitting Reports and Other Documents Under Martial Law or in Wartime, all nonbank financial services providers that, for objective reasons, could not duly submit reports, should do so within three months after the martial law is suspended or lifted. In particular, they are required to submit to the regulator the following documents for the whole period of delays in reporting:

  • reporting data (other than financial statements and consolidated financial statements), requirements to which are set out in Rules No. 123
  • report on corporate governance, requirements to which are prescribed by the Law of Ukraine On Financial Services and State Regulation of Financial Markets
  • financial statements (consolidated financial statements), including the annual financial statements and consolidated annual reports together with an independent auditor’s report, management report (consolidated management report) that are prepared and submitted in line with the Law of Ukraine On Accounting and Financial Reporting in Ukraine and Procedure for submitting financial reporting approved by Resolution No. 419 of the Cabinet of Ministers of Ukraine dated 28 February 2000. In particular, nonbank financial institutions and companies other than financial institutions that have the right to provide certain financial services and have chosen to prepare financial statements and consolidated financial statements based on the financial reporting taxonomy in line with the international standards should prepare and submit such statements in unified electronic format to the center for collecting financial statements, the operational management of which is carried out by the National Commission on Securities and Stock Market.

The NBU’s web portal will operate as usual. It will be open for uploading the files with the reporting data within the set time limits (files should be uploaded in sequential and chronological order according to a reporting date).

Disclosure of other information

Nonbank financial services providers are required to disclose reporting and other information in line with the Regulation On Disclosure of Information by Nonbank Financial Institutions approved by NBU Board Resolution No.114 dated 5 November 2021 (as amended) within four months after the martial law is lifted in Ukraine.

It should be mentioned that under the martial law or the state of war, the NBU will not inspect timeliness and completeness of reporting.

We would like to additionally inform insurance market participants that the NBU together with the Ministry of Finance of Ukraine is considering the possibility of suspending the implementation of IFRS 17 Insurance Contracts in Ukraine.

For reference

Despite martial law, it is important for the NBU to obtain the timely information about financial standing and performance indicators of the nonbank financial services market.  This will allow to provide a swift response to challenges in the operation of market participants, by amending the NBU’s laws and regulations.



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